Healthy Indoors Magazine - USA Edition

18 | August 2019 fl oors and interior window sills are equal to or great- er than 10 mg/ft2 for fl oors and 100 mg/ft2 for interior window sills, respectively; * * * * * § 745.325 Lead-based paint activities: State and Tribal program requirements. * * * * * (e) (1) A State or Tribe with a lead-based paint activities program approved before the effective date of the revi- sions to the lead-based paint activities program require- ments in subpart L of this part must demonstrate that it meets the requirements of this section in a report that it submits pursuant to § 745.324(h) but no later than two years after the effective date of the revisions. * * * * * From the FR, fi rst page of footnote 4 (at page 32632, underlining by author) DATES: This fi nal rule is effective January 6, 2020. So, let's now summarize what we currently have between HUD and EPA; • HUD has lowered the values for 'dust-lead action levels' and 'lead clearance action levels' for two specifi c grants. NOT all HUD or federally funded work in target housing. Nor do these values currently apply to EPA regulated work. • EPA will be lowering the LBP dust hazard levels for risk assessments in January of 2020. EPA did not address or alter fi nal clearance dust sampling, soil issues or any oth- er testing, yet, but soon will. And that's it! Let us now look at the laboratory reporting issue. For many years the generally employed method for LBP dust wipe sample analysis has been NIOSH method 7082, Lead by Flame Atomic Absorption Spectroscopy (fl ame AA)6. But, this method has limits of how low one can report limits of detection (LOD) and limits of quantitation (LOQ). I'll rely on a few footnotes for technical accuracy. Much of this in- formation is found in HUD's document at footnote 3. I'll use some of that information and try to fi ll in the blanks to make sense of this issue. Let's go backwards a bit to footnote 3, further from HUD's document 2017-01 Rev 1; "Laboratories that ana- lyze samples from target housing for lead in dust samples must be recognized by EPA under its National Lead Lab- oratory Accreditation Program (NLLAP)." A list of EPA-rec- ognized NLLAP laboratories is provided to the public so homeowners, lead inspectors and contractors can fi nd Then the EPA… The EPA has recently announced that they will lower lead dust risk levels for risk assessments starting on January 6, 20204. There is another team at the EPA currently work- ing on new lead dust levels for clearance testing and those levels are expected to be the same as the clearance levels required for OLHCHH's LBPHC and LHRD grantees…but not yet. For the sake of brevity, the referenced document at footnote 4 will explain the details of the rulemaking process. They were to also evaluate clearance levels for post lead hazard control activities, as well as lowering the defi nition of what constitutes LBP. The agency declined to pursue either of those two avenues. See the document for the EPA's ex- planations. LBP poisoning advocates are not pleased with EPA's decision on these two issues. But, on to what the agency will require. A few selected items from the EPA Federal Register (FR) notice at footnote 4. These items start on page 32648: § 745.65 Lead-based paint hazards. * * * * * (b) Dust-lead hazard. A dust-lead hazard is surface dust in a residential dwelling or child-occupied facility that contains a mass-per-area concentration of lead equal to or exceeding 10 mg/ft2 on fl oors or 100 mg/ft2 on interior window sills based on wipe samples * * * * * � 3. In § 745.227, paragraph (h)(3)(i) is revised to read as follows: § 745.227 Work practice standards for conduct- ing lead-based paint activities: target housing and child-occupied facilities. (h)(3)(i) In a residential dwelling on fl oors and interior window sills when the weighted arithmetic mean lead loading for all single surface or composite samples of

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